Nevada v. Jackson

The exclusion of extrinsic evidence relating to prior acts of a witness is not a violation of the constitutional right to present a complete defense.

Respondent was arrested, charged and convicted of rape. During the trial Respondent wanted to offer extrinsic evidence to support the defense that the sexual assault was fabricated in order to control Respondent. The trial court allowed for "wide latitude" when cross examining the victim but would not allow for the defense to call any of the officers as witnesses or admit their police reports. Respondent appealed conviction and argued that the trial court's refusal to admit evidence was a violation of Respondents constitutional right to a complete defense. The Nevada Supreme Court rejected this argument. Respondent filed a federal habeas petition. The Ninth Circuit applied the Anti-Terriorism and Effective Death Penalty Act (AEDPA) deferential standard of review and reversed stating it believed that the extrinsic evidence was critical to Respondent's defense and excluding it kept the Respondent from exercising the right to present a complete defense.

The AEDPA allows a federal habeas court to reverse a state court's application of federal law if "there is no possibility fair minded jurists could disagree that the state court's decision conflicts with [The Supreme Court]'s precedents." The Supreme Court found that the Nevada Supreme courts application of precedent was "reasonable." The Supreme Court reversed the the Ninth Circuits judgment and remanded for further proceedings.